Snyder v. Gladeview Healthcare Center
The trial commissioner lacked legal authority to enforce a settlement agreement allegedly reached between the claimant and respondent, which the respondent did not execute prior to the claimant's death. Joyce Snyder suffered a compensable injury in 1997, working as a nurse for the respondent Gladeview Healthcare Center. Voluntary agreements were approved. Snyder did not return to gainful employment following a 2000 surgical procedure. She attained maximum medical improvement on July 17, 2006 with a 70 percent permanent partial disability. Prolonged settlement discussions ensued. In January 2011, counsel for both parties agreed in principal to a $108,161 settlement amount, which was reduced to writing. On Feb. 5, 2011, Snyder died for reasons unrelated to her compensable injury. Snyder's surviving spouse sought to enforcement the agreement. The trial commissioner, noting that the settlement was never properly before a commissioner, nor was it approved prior to the claimant's death, nor did the respondent sign the settlement documents, concluded that it was not enforceable and dismissed the claim. The claimant appealed arguing, primarily, that the 2001 Appellate Court case of O'Neil v. Honeywell, Inc., compelled the trial commissioner to approve the agreement. The Compensation Review Board affirmed the finding and dismissal. The board declined to apply O'Neil when the trial commissioner never approved the original agreement. In O'Neil, the agreement was presented to the commission and fully executed by the respondent. The respondent could not belatedly rescind approval after learning of the claimant's later death. The reasoning was that once a party executed an agreement and affirmatively represented that it was reached openly and fairly, one was estopped from subsequently trying to set aside the agreement for fraud or mistake. Decades of precedent supported the commissioner's conclusion that absent express approval by the commission, a settlement is not enforceable. The commissioner placed great weight on the fact that the respondent never executed the agreement while the claimant was alive and declined to execute it after her death. A trial commissioner may properly determine that when an agreement which is not executed by both parties is presented to the commission for approval, it is axiomatic that both parties must assent to its approval at that hearing.